Cultural Resources & Nine Step Planning Process Crosswalk

Natural Resources Conservation Service (NRCS)recognizes that cultural resources, including historic properties, are an integral part of our national heritage and recognizes its responsibilitiesto consider these resources during conservation and program planning and implementation. It is essential that NRCS conservation planners and technical support staff have the ability to recognize physical evidence of cultural resources in the field and to be able to determine if agency actions or practices resulting from technical or financial assistance are undertakings that have the potential to effect existing or potentially eligible historic properties. The presence of cultural resources, and/or existing or potentially eligible historic properties within the Area of Potential Effect (APE) shall be determined early in the conservation planning and environmental evaluation process for all assistance activities that are classified as an undertaking.

NRCS policy related to its responsibilities toward the protection of historic and cultural properties is found under General Manual (GM 420, Part 401 (Subparts A – D). The National Cultural Resources Procedures Handbook (NCRPH), Title 190-VI is the procedural reference and guidance on processes that NRCS, partners and consultants shall use to identify, evaluate and protect cultural resources, including historic properties, in compliance with the National Historic Preservation Act (NHPA –16 U.S.C. 470f, as amended) along with other related authorities. The Florida State Level Agreement (SLA) between NRCS and the Florida State Historic Preservation Office (SHPO) establishesstreamlined procedures and compliance requirements specific for use by NRCS in Florida. The SLA is located as a Florida Amendment to the NCRPH, see 190-VI-NCRPH, Amendment FL-2, June, 2008.

Required Training

It is essential that conservation planners and field technical support staff have adequate training and expertise to fulfill NRCS’s requirements to protect historic and cultural properties when providing technical and financial assistance. Formal training outlined below is required for all NRCS staff to obtain cultural resource planning authority to consider and document cultural resource information on the FL-CPA-46, Cultural Resource Site Report, prepare and maintain records of cultural resource decisions and support data, and to effectively communicate with landownersrelative to cultural resource concerns on their property.

  • NRCS AgLearn, web-based Cultural ResourcesTraining Modules 1-6
  • NRCS Cultural Resources Training, Classroom & Field Modules 7-8

Table 1 identifies key actionsoutlined in agency policy and procedures that need to be performed to ensure that NRCS functions within the intent of Federal, Tribal, state,and local laws to protect cultural resources and historic properties. Key staff and actions are outlined relative to when these procedures should be accomplished in accordance to the NRCS 9-Step Conservation Planning process. Also provided are references cited within NRCS policy (General Manual), State Level Agreement (SLA) or National Cultural Resources Procedures Handbook (NCRPH) to help guide field staff to more information related to each action.

Table 1: Key Tasksby Staff, Conservation Planning Step and Reference

Actions / Staff/Office / Timeline in Association with the 9-Step Conservation Planning Process / Reference
Considerationof cultural resources & historic properties within the APE, or its approximate vicinity (500 feet) shall be accomplished by properly trained staff.This includes conducting a cultural resource review and surface field inspectionand appropriately documented on the FL-CPA-52, and as appropriate the FL-CPA-46.
When the likelihood of an affect will occurto a cultural resource or when cultural resources are likely to be present, a cultural resource investigation must be performedby the NRCS SO-ECS Cultural Resource Specialist.
On WRP project sites, see Special Procedure requirementslocated in the NCRPH. / DC or conservation planner/ Field Office
NRCS SO-ECS CRC shall initiate consultation with State Historic Preservation Office (SHPO) and Tribal Historic Preservation Office (THPO). / Shall be conducted early in the Conservation Planning Process, and prior to completing Step 3, “Inventory Resources” All information regarding cultural resources are to be placed in a secure location and are exempt from FOIA. / GM-420-Subpart C
401.21 B (3)
State Level Agreement 2 A
State Level Agreement 2 B
NCRPH Part 601.22 (B) 6, Florida Supplement
Complex Conditions or known existence of cultural resource sites, orother concerns,contact the NRCS SO-ECS Cultural Resource Coordinator immediately. / DC or conservation planner/ Field Office / As soon as conditions are known and prior to completing Step 3, “Inventory Resources” / SLA 1 A
Identificationand delineationof cultural resources & historic properties can only be verified by the NRCS SO-ECS Cultural Resource Specialist. / Cultural Resource Specialist/SO-ECS / Schedule as soon as possible and prior to completing Step 4, “Analyze Resource Data” / GM-420-Subpart C
401.21 B (4)
Evaluation & Documentation of conservation planning alternatives to avoid an undertaking will be based upon on-site cultural resource investigations conducted by the NRCS SO-ECS Cultural Resource Specialist. / Cultural Resource Specialist/SO-ECS / Report back to NRCS SO-ECS CRC and Field Office prior to completing Step 5, “Formulate Alternatives” / GM-420-Subpart C401.21 B (5)
GM-420-Subpart C 401.30 C (1) & (2)
Compliance Documentationis preparedrecords maintained of all cultural resource decisions and supporting data. / DC or conservation planner/ Field Office / Incorporate findings into agency record files within the Field Office, prior to completing Step 7, “Make Decision” / GM-420-Subpart C 401.30 A
Consultation shall include NRCS SO-ECS Cultural Resource Specialist determination and analysis to the SHPO/THPO/Tribe. / NRCS Cultural Resource Coordinator/SO-ECS / Generate correspondence and obtain feedback prior to completing Step 8, “Implement the Plan” / GM-420-Subpart C 401.21 B (2)
GM-420-Subpart C 401.30 B
Mitigation Plan,shall be prepared for all historic properties that cannot be avoided. Must be completed before an irreversible action has been taken. / DC or conservation planner with NRCS Cultural Resource Specialist & Coordinator/SO-ECS / Prepare mitigation and modify conservation plan to reflect mitigation procedures prior to completing Step 8, “Implement the Plan” / GM-420-Subpart C 401.30 C (3) NCRPH Part 601.27
Withdrawal of Assistance shall be implemented if the resources within the APE, can be avoided or treated, and will be adversely affected, and the mitigation plan is not accepted by the landowner. / DC or conservation planner / Must inform Landowner within five (5) working days of decision, and must be completed prior to Step 8, “Implement the Plan” / NCRPH Part 601.27

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